Placentia Bay Atlantic Salmon Aquaculture Project · Grieg Newfoundland Salmon Ltd. (GNS) realizes...

Grieg Newfoundland Salmon Ltd.

2016

Grieg Newfoundland Salmon Ltd.

Marystown, Newfoundland

8/19/2016

Placentia Bay Atlantic Salmon Aquaculture Project

Women’s Employment Plan

Grieg Newfoundland Salmon Ltd. i

Table of Contents 1.0 Introduction ...................................................................................................................................... 1

1.1 Project Workforce and Schedule ................................................................................................ 3

1.2 Employment Diversity Principles and Commitments................................................................. 6

2.0 Community and Communication ..................................................................................................... 7

2.1 Community ................................................................................................................................... 7

2.2 Communication ............................................................................................................................ 8

3.0 Land Based and Marine Based Operations ................................................................................... 10

3.1 Recruitment ................................................................................................................................ 10

3.2 Hiring ........................................................................................................................................... 12

3.3 Career Planning .......................................................................................................................... 13

3.4 Retention .................................................................................................................................... 14

4.0 Workplace Policies and Conditions ............................................................................................... 15

4.1 Non-discrimination Policies ....................................................................................................... 16

4.2 Contractors and Partner Companies ......................................................................................... 17

5.0 Monitoring and Reporting ............................................................................................................. 18

Grieg Newfoundland Salmon Ltd. 1

1.0 Introduction

Demand for quality seafood is increasing as is the concern over food security. Newfoundland, as an island,

is very much dependent on food importation and as such, risks food shortages should there ever be a

disruption in either supply from mainland North America or with current transportation methods such as

ferries and roads. As well, there are global concerns with regard to supplies for fresh quality seafood.

However, Newfoundland has tremendous resources available that are currently being underutilized that

could not only help alleviate concerns with food security but also assist with the increasing demand for

high quality seafood products in North America and potentially even globally.

Grieg Newfoundland Salmon Ltd. (GNS) realizes this potential for Newfoundland and is pursuing a state-

of-the art Recirculating Aquaculture System (RAS) for culturing triploid Atlantic salmon (Salmo salar) smolt

in Marystown, Newfoundland and Labrador (NL) with on-growing marine cage sites in Placentia Bay, NL,

and processing into high end quality salmon fillets and other speciality products at a facility in St.

Lawrence, NL (Figure 1).

Figure 1: Location in Placentia Bay Newfoundland of Grieg Newfoundland Salmon Ltd. operations


Grieg Newfoundland Salmon Ltd. (the holding company in Newfoundland for Grieg Newfoundland AS of

Norway (Grieg Holding AS 40%, Kvasshøgdi AS 40%, and Ocean Choice International (OCI) 20%)) has three

subsidiary companies, Grieg NL Nurseries Ltd. is the land based hatchery operations, Grieg NL Seafarms is

the marine based sea cage site and Grieg NL Development Ltd (Figure 2). The Grieg group of companies

are one of the world’s leading fish farming enterprises specializing in Atlantic salmon, with operations in

Norway, British Columbia and Shetland, UK. GNS’s focus is on sustainable use of resources while achieving

profitable growth.

Figure 2: Corporate Structure of the Grieg Group of Companies

This project has strong potential in terms of export market opportunities and economic benefit, especially

in outport Newfoundland. An operation of this size will provide very significant employment

opportunities, resulting in a much needed major boost to the current economy of NL and providing

prospects for graduates to utilize their skills and knowledge in their home province. Newfoundland is

world renowned for some of its training facilities and the graduates that it produces. The Fisheries and

Marine Institute of Memorial University is one such training facility that GNS has already utilized for

recruiting skilled employees and will continue to utilize this and other training facilities in the province for

its workforce.


The proposed Project was registered for Environmental Assessment (EA) review under the Newfoundland

and Labrador Environmental Protection Act (NL EPA, Part 10) in February 2016. Following governmental

and public review of the EA Registration, the Minister of Environment and Conservation announced on

July 22, 2016 that the Project had been released from the EA review process, subject to a number of

associated terms and conditions. These included the following:

Prior to the commencement of construction activities, the proponent must submit a Women's

Employment Plan for the project to the Women's Policy Office that meets the approval of the

Deputy Minister.

The preparation and submission of this document is intended to address the above noted condition of EA

release for the Project.

This Plan provides an overview of the various measures that GNS will take to help ensure the involvement

of a diverse and inclusive workforce during the implementation phase of the Project. This includes

measures to enhance and maintain the participation of women in the Project during its various phases.

1.1 Project Workforce and Schedule

The subsidiaries of GNS will be Grieg NL Nurseries Ltd., a land based hatchery and nursery and Grieg NL

Seafarms Ltd., a marine based sea cage grow out site. Each of these subsidiaries will be structured with a

senior management team overseeing staff.

Construction of the land based hatchery and nursery is slated to begin in the Fall of 2016 and continue in

phases through 2021. At its peak construction period in 2017-2018, it is estimated that upwards of 200

persons will be working on project-related construction activities. Once the land based hatchery and

nursery facility is fully operational by 2018, an estimated 36 employees will be working there in

permanent, year-round positions. (Table 1).

GNS will also have four marine based areas for continued grow out of the salmon to market size. Once full

production is reached in 2021 and all four marine areas are in use, it is expected that 137 employees will

be working at these marine sites in Placentia Bay (Table 1).


Table 1: Estimated Full Time (FT) and Part Time (PT) employees required for GNS Land Based and Marine Based Construction and Operations, 2016-2022

Occupation

NOC Code

(2011) FT/PT

Max # of

Positions

GNS or

Contractors

(CT)

Years

Required

Engineering Manager 0211 FT 3 CT 2016-2021

Civil Engineers 2131 FT 2 CT 2016-2021

Civil Engineering

Technologists 2231 FT 2 CT 2016-2021

Drafting

Technologists/Technicians 2253 FT 1 CT 2016-2021

Land Survey

Technologists/Technicians 2254 FT 1 CT 2016-2021

Construction Inspector 2264 FT 4 CT 2016-2021

Electrical Power Line and

Cable Workers 7244 FT 5 CT 2016-2021

Telecommunication Line and

Cable Workers 7245 FT 5 CT 2016-2021

Steamfitters, Pipefitters and

Sprinkler System Installers 7252 FT 20 CT 2016-2021

Welder 7237 FT 10 CT 2016-2021

Carpenters 7271 FT 20 CT 2016-2021

Concrete Finisher 7282 FT 20 CT 2016-2021

Heavy Equipment Mechanics 7312 FT 4 CT 2016-2021

Crane Operators 7371 FT 2 CT 2016-2021

Truck Drivers 7511 FT 5 CT 2016-2021

Heavy Equipment Operators 7521 FT 4 CT 2016-2021

Construction Labourers 7611 FT 92 CT 2016-2021

TOTAL 200

Senior Management 0016 FT 1 GNS 2016-

Maintenance Manager 0714 FT 1 GNS 2016-

Production Manager 0911 FT 1 GNS 2016-

Aquaculture Managers 0823 FT 7 GNS 2016-

Aquaculture Technicians 2221 FT 16 GNS 2017-

Aquaculture Technicians 2221 PT 6 GNS 2017-

Welder 7237 FT 1 GNS 2017-

Heavy Equipment Operators 7521 FT 1 GNS 2017-

Air Conditioning Mechanic 7313 FT 1 GNS 2017-

Power Systems Electrician 7202 FT 1 GNS 2017-

TOTAL 36

LAND BASED HATCHERY AND NURSERY PHASE

Construction Phase

Operational Phase


A lumpfish hatchery is also planned to be used as a cleaner fish in the cages with the salmon as a natural

means of controlling sea lice infestations. It is expected that by 2017 the lumpfish hatchery will be

employing 10 individuals (not employed directly by GNS).

In 2019, the first salmon are expected to be harvested and subsequent years will see an increase in

processing needs as all four marine sites are harvested. By 2022, it is expected that 426 individuals will be

working in the NL seafood processing will be involved in the processing and services needed to bring GNS

Atlantic salmon products to market.

Occupation

NOC Code

(2011) FT/PT

Max # of

Positions

GNS or

Contractors

(CT)

Years

Required

Captains 8261 FT 1 CT 2017

Engineering 0211 FT 1 CT 2017

Deck Hands 8441 FT 6 CT 2017

Electrical Industrial 7242 FT 1 CT 2017

Welder Operator 7237 FT 1 CT 2017

Heavy Equipment Mechanic 7312 FT 1 CT 2017-

Crane Operator 7371 FT 1 CT 2017-

TOTAL 12

Senior Managers 0016 FT 2 GNS 2016-

Supervisor General Officer 1211 FT 1 GNS 2016-

Supervisor Financial 1212 FT 1 GNS 2016-

Human Resources Officer 1223 FT 1 GNS 2016-

Administrative Assistant 1241 FT 1 GNS 2016-

Maintenance Manager 0714 FT 1 GNS 2016-

Production Manager 0911 FT 1 GNS 2016-

Aquaculture Managers 0823 FT 7 GNS 2016-

Aquaculture Technicians 2221 FT 33 GNS 2017-

Crane Operator 7371 FT 2 CT 2017-

Captains 8261 FT 16 GNS & CT 2017-

Deck Hands 8441 FT & PT 36 GNS &CT 2017-

Welder 7237 FT 1 CT 2017-

Heavy Equipment Mechanics 7312 FT 6 CT 2017-

Power Systems Electrician 7202 FT 3 GNS 2017-

Aquaculture Labourers 8613 FT & PT 25 GNS 2017-

TOTAL 137

Operational Phase

MARINE BASED SEA CAGE PHASE

Installation Phase


1.2 Employment Diversity Principles and Commitments

GNS is committed to diversity in the workplace and believes strongly in non-discrimination with a focus

on personnel that are committed, dedicated and knowledgeable in their area of expertise or have a strong

willingness to learn and grow. It is these qualities that GNS intends to pursue to build a team that will

continue to support the Grieg group of companies values and principles. GNS recognizes that diversity in

the workplace promotes not only different perspectives but also opinions that can in turn provide varying

approaches and solutions and therefore will be embracing such diversity in its workforce.

GNS has developed this Women’s Employment Plan (WEP) for Grieg Newfoundland Salmon Ltd. and its

subsidiary companies. This plan is intended to encourage a proactive approach toward a workplace

environment with policies and practices that promote moral fairness and provide a work environment

free from harassment and discrimination. Although traditionally male-dominated, aquaculture and other

marine related careers have in recent years seen an increase in women in these non-traditional roles. This

is reflected in the current workforce of GNS, with seven employees, four of whom are women (thereby

representing 57% of the current workforce). GNS recognizes that talent is not gender specific, and as such

will promote a workplace culture that is supportive of women in order to attract and retain talented

individuals that can contribute to the success of GNS.

GNS expects all its employees to support this WEP by actively discouraging any behaviour or language that

can be considered gender insensitive or not respectful of others. In addition, all managers of GNS will be

expected to ensure that staff are aware of equality in the workplace, participate in any training programs

offered by GNS to increase awareness of gender sensitivity and contend in a timely and appropriate

manner with any personnel that exhibits gender insensitive behaviour.

GNS has developed a number of strategies and initiatives to aid in reaching our goal of an inclusive and

reflective workforce. Striking a balance between merit and equality is paramount for our organization.

Establishing the proper framework for gender equality will be met through the following responsibilities

and beliefs by senior management in our planning and our operations:

Senior management is committed to gender equality

GNS has sufficient resources and knowledgeable personnel, along with a positive atmosphere

that will promote gender equality

There are accountability frameworks which ensure that the gender equality policy is

implemented


Gender equality is treated as an objective in and of itself

Gender equality is recognized as relevant to every aspect of operations

Gender analysis is integrated into Project planning

Methods are identified to ensure there is broad participation of women and men as decision

makers in the planning process, and

Clear, measurable, and achievable gender equality results are developed in the earliest phases

of the process

2.0 Community and Communication

GNS is prepared to learn from other organizations within the aquaculture industry and other sectors, in

order to establish, implement and maintain a positive approach to employment diversification. GNS is

committed to working with the community as well as the public sector, government agencies, various

women’s groups such as the Newfoundland and Labrador Organization for Women Entrepreneurs

(NLOWE), Provincial Advisory Council on the Status of Women, Women Interested in Successful

Employment (WISE), Women in Resource Development Corporation, Women in Science and Engineering

Newfoundland and Labrador, the NL Department of Advanced Education, Skills and Labour and

educational institutions such as the Fisheries and Marine Institute to maximize opportunities for women.

2.1 Community

GNS is committed to supporting local communities, particularly with regard to employment opportunities

for women. Specifically, GNS will:

Work with education and training institutions and relevant industry and stakeholder organizations

to generate overall awareness of job opportunities associated with the Project and the necessary

skills required.

Participate in information sessions at the community level, with the assistance of government and

non‐government stakeholders, which are responsive to women needs.

Provide associated career information to guidance counsellors in secondary school systems.

Provide support for Women’s Job Information Workshops.

Incorporate gender based analysis information gathered from external stakeholders into the

company’s policy and workplace design decisions.


Link with and provide support to women’s organizations / networks, which support the

employment of women.

Meet with community groups and women’s organizations to review existing and potential

women’s employment initiatives and strategies.

Profile female employees working in non-traditional occupations in internal and external

company communications material.

Continue to develop and maintain a corporate culture and work environment within the company

that facilitates the achievement of the career goals of women, and provides them with the training

and support they need to help them meet their goals and the corporation's business objectives.

This includes continuing to offer assistance programs and mentorship to provide employees with

an opportunity to enhance knowledge and skills relevant to their work and to advance within the

organization according to their goals and aspirations.

2.2 Communication

GNS is taking a hands-on approach to encourage women’s participation in non‐traditional roles, it also

recognizes that in order to significantly affect women’s employment levels, industry and government

organizations will have to work together to promote a positive message. This message should outline the

advantages of gender diversity in the workplace in addition to referencing the current levels of

employment by women in the various trade and professional occupations.

To support gender diversity at the local level, as outlined throughout the Women’s Employment Plan, GNS

will develop and utilize the following tools as part of its own communications strategy.

GNS will provide women’s organizations with Project information to ensure members of key

target audiences are informed of available employment and business opportunities. The company

will also support successful contractors and subcontractors to provide timely employment

information to relevant stakeholder organizations.

Working with stakeholder organizations to provide information and assistance to help ensure that

women and other members of underrepresented groups understand the job application process,

including the role of contractors and unions, and how to register and apply for Project-related

positions.


The use of appropriate language and imagery in all job ads and other communications to

encourage women to apply for job opportunities. A gender equity and diversity statement will be

included in any such promotional materials related to the development of the Project.

Any Project-related promotional and communications materials will use positive images and

articles / profiles regarding the involvement of women in working on the Project and in the

aquaculture industry as a whole.

GNS will include statements in Project-related tender documents to inform potential contractors

of their obligation to assist with maximizing the involvement of women and in reporting the

results of efforts and outcomes with regard to their employment.

Working with high schools and post secondary institutions in the area to promote the aquaculture

industry as a viable career for young women considering post-secondary education options.

Reinforcing key messages and promote women’s employment, particularly in non-traditional

roles, in the local community.

Conducting school visits at the grade and post secondary levels to promote employment

opportunities in the aquaculture industry. When conducting such visits, GNS will use female role

models employed by the company.

Reinforce key messages promoting women’s employment in media interviews and presentations.

Sponsor programs designed to promote women’s employment (e.g. Women in Science and

Engineering (WISE) program.)


3.0 Land Based and Marine Based Operations

3.1 Recruitment

GNS is committed to being an equal opportunity employer devoted to gender diversity with competitive

benefits, compensation, and the continuous improvement associated with the advancement of

employment of women within the organization. This includes with respect to its own direct workforce, as

well as supporting contractors and subcontractors to maximize the involvement of women in the Project’s

labour force where qualified for Project requirements.

To support the recruitment of women in its workforce GNS will adhere to the following policies and

practices:

Commit to working with training institutions in the province (including the Fisheries and Marine

Institute) to support the integration of female registered students and their transferrable skills

into the GNS workforce. These programs at training institutes such as the Fisheries and Marine

Institute are skills and trades that are applicable to the Grieg group of companies and have

representation of females in all fields (Table 1). GNS will commit to coordinating with these

institutes for recruitment fairs as well as work term placements for female graduates.

Table 1: Enrollment by gender for the fall 2014 and fall 205 Diploma and Advanced Diploma programs at the Fisheries and Marine Institute of Memorial University of Newfoundland

Marine Institute Program Total Enrollment (# Females)

Fall 2014 Fall 2015

Advanced Diploma 24 (7) 17 (6)

Food Safety 12 (3) 9 (2)

Sustainable Aquaculture 7 (2) 3 (2)

Water Quality 5 (2) 5 (2)

Diploma in Technology

Food Technology 15 (8) 14 (6)

Year 1 4 (4)

Year 2 2 (1) 4 (4)

Year 3 5 (1) 1

Year 4 4 (2) 9 (2)


Marine Institute Program Total Enrollment (# Females)

Fall 2014 Fall 2015

Marine Environmental

Technology

35 (30) 30 (24)

Year 1 16 (13) 9 (6)

Year 2 11 (9) 12 (10)

Year 3 8 (8) 9 (8)

Source: Fisheries and Marine Institute, School of Fisheries, 2016

In addition to the various communication measures described in the previous section, GNS will also

implement the following related to recruitment of the Project workforce:

Develop training sessions to educate supervisors and managers in the recruitment processes to

guarantee practices free of gender prejudice.

Have a hiring panel consisting of men and women who support gender diversity.

Provide equal worth to job qualifications and work experience despite gender.

Consider, where possible and practical, job shadowing and on‐the‐job opportunities to women

enrolled in science, technology fields, and industrial trades where women are underrepresented

(WISE program, student work terms).

Continue to practice a zero tolerance policy on discrimination and harassment.

Continue to support and promote hiring practices that are consistent with a healthy and

productive working environment.

Ensure that women are appropriately represented throughout the workplace.

Conduct exit interviews for analysis and feedback into the Company’s recruitment and retention

plan.

The Burin Peninsula is an area of traditionally high Employment Insurance (EI) prevalence and GNS will

have a significant positive impact on the labour force and ultimately the EI use in the region. The following

table depicts the EI beneficiaries reported for the entire Burin Peninsula 2012-2014. As indicated in Table

2, 40% (4,770 individuals) of the labor force on the Burin Peninsula filed EI claims in 2014 with 38 % (1,805

individuals) of these beneficiaries being female. The very nature of this work will have positive impacts on

the female workforce and particularly the prime labour force. Since operations for GNS will be full time


and not seasonal, this project could employ persons, particularly females in small communities on the

Burin Peninsula where employment is often difficult to find and can provide them with long term

employment security as opposed to relying on EI benefits for a portion of the year. In addition, the

processing plant will create jobs in St. Lawrence and Fortune, two towns where at the present there is

very little new employment activity.

Table 2: Prevalence of EI Beneficiaries Burin Peninsula, Newfoundland 2012-2014

3.2 Hiring

The hiring process that GNS and contractors utilize must ensure that fair and equitable access is provided

to all eligible candidates. Further, all employees must accept the importance and value of gender diversity

in establishing a healthy productive workplace. Currently GNS has seven employees, four of which are

women. In the future GNS intends to hire 24 full time employees and six temporary employees for land

based operations with a 25% female target.


In support of this objective, GNS will implement the following initiatives:

Ensure job advertisements state that GNS is an equal opportunity employer and will show women

engaged in work when graphics / pictures are utilized.

Participate in career fairs and school visits. Utilize women employed in non-traditional

occupations and other success stories to support such efforts.

Provide work term opportunities to women enrolled in cooperative education programs in the

science, trades and technology fields.

Ensure that individuals involved in the recruitment process are familiar with applicable Federal

and Provincial Human Rights, labour, occupational health and safety, worker’s compensation and

other relevant legislation through the distribution of published educational material.

3.3 Career Planning

GNS is focused on strengthening, mentoring, and coaching structures that provide employees with the

knowledge, skills and motivation to accomplish short and long terms goals within the aquaculture

industry. GNS will use a series of management programs to fully support women at all levels within the

organization through training, workshops, policies, etc. as they express interest to advance in their

careers. The programs will be modified as feedback is received from employees and from monitoring

developments in technology and learning from other organizations.

In addition, GNS will support women’s advancement in their careers by:

Developing and maintaining an internal commitment from managers and supervisors to identify

potential employees for higher‐level positions within the company.

Promoting a culture that supports a positive relationship between men and women.

Providing opportunities to enhance women’s professional development.

Identifying and addressing barriers that can be deterrents to peak performance.

Allocating required resources, including mentors, to assist employees in career planning and

aspirations.

Examining innovative ways for employees to network and support career growth and planning

for women.


GNS’s Human Resources Department will take the necessary steps to align operational requirements with

employee needs. GNS is confident that with sound business practices and clear company goals gender

diversity will play an important role in the Grieg group of companies’ workforce in addition to the training

future of leaders.

3.4 Retention

GNS will develop a strategy to address the challenge of employee retention in the long-term in accordance

with GNS’s overall Human Resources philosophy. The major challenge for employers and workers is the

retention of women in traditionally male-dominated industries and occupations. A key component to

improve the situation is again the effectiveness of the gender analysis information where women and

men working together contribute to policy and workplace conditions decision-making. GNS’s plan for

gender diversity starts with the premise that both men and women must be involved in building a

welcoming and productive workplace.

In addition to the recruitment of women, GNS has also initiated policies and practises to retain and

promote its existing women’s work force. These include but are not limited to:

A zero tolerance approach to gender‐related harassment.

Provide work schedules that promote better work/life balance and career path planning that offer

the flexibility necessary to attend to family responsibilities.

Reduce sources of unnecessary stress in the workplace such as harassment and work‐family

conflict.

An employment equity policy throughout GNS.

Work with contractors to ensure consistency in policy development and implementation.

Hire qualified women to be developed as trainers and mentors where possible.

Ensure that the compensation system provides for equal pay for equal work.

GNS will continue to communicate and update its policies with regards to gender diversity and women’s

employment.

By implementing the above policies and practices GNS believes that it is working toward a better, healthier

working environment free of any form of harassment and discrimination towards women. Further details


on GNS plans to help ensure a diverse, safe and respectful workplace for its Project are detailed in the

sections that follow.

4.0 Workplace Policies and Conditions

GNS has developed a number of workplace policies and practices to be adopted by the Company’s Human

Resources Department to ensure women are not only represented within GNS and its subsidiaries but

also will have equality in all aspects of the business including compensation, respect, and dignity. These

initiatives include but are not limited to:

1. GNS has developed a Code of Conduct and Ethics that supports women in the workplace.

Employees will be expected to adhere to this Code and act in a positive manner in all that they do

and say. Behaviour or conduct that is offensive including any form of harassment will not be

tolerated and disciplinary action, including termination if necessary, will be taken.

2. Ensuring that all employees, contractors and subcontractors are aware of GNS standards,

practices and policies related to the employment and involvement of underrepresented groups.

These will be clearly documented and displayed at the Project worksite.

3. All Project workers will be provided with an orientation and induction program that includes

health and safety, cultural awareness, gender sensitivity, and environmental awareness training.

4. Strict enforcement of corporate policies and practices related to women’s employment and

respectful workplaces, and a requirement for contractors to have an associated standard with a

zero tolerance for harassment.

5. All Project facilities will comply with applicable regulatory requirements, including those related

to accessibility and gender, as a minimum. This will include providing gender separate

accommodations, washroom facilities and locker or change rooms wherever possible, as well as

correctly fitting personal protective equipment. and appropriate tools and equipment to

accommodate women’s needs where feasible.

6. The use of gender inclusive / neutral language in all written correspondence and verbal

communications with employees. Also, ensuring that gender equity and workplace diversity is

evident in any images used in regular employee communications and notices.

7. GNS employees will be expected to use gender sensitive language in all their work activities.

8. GNS will ensure that opportunities exist for representation by women on all workplace

committees where interest exists.


9. Providing on-going assistance and support in the workplace, including on-site workplace

committee(s), employee assistance programs, and mentoring for women.

10. Ensuring that applicable policies and practices related to inclusion and diversity are known and

communicated, including clearly outlined incident reporting procedures.

11. Providing supervisors with respectful workplace training to enable them to address any situations

that may arise in a timely, safe and appropriate manner.

12. Continual reinforcement of Project-related policies and requirements about gender equity and

diversity through regular tool box talks, lunch and learns, supervisory training, meetings, worksite

posters and other such means.

13. Ensuring adequate and appropriate security onsite at all times, including that worksites, common

areas and parking lots are well lit to support personal safety.

14. Conducting, through the HR Department, exit interviews with all employees (including females)

and using this information to identify and address any identified concerns, including those that

may be related to workplace conditions.

4.1 Non-discrimination Policies

GNS recognizes and respects the Canadian Human Rights Act which prohibits employers from

discriminating against individuals in hiring, firing, or the terms and conditions of employment because of

certain personal characteristics. GNS expects this same commitment from its employees in all business

activities. GNS has developed a Code of Conduct and Ethics that will also apply to gender in the workplace

in which GNS clearly states that it expects the following behaviour from all its employees in all business

activities:

Respect the dignity of all individuals and ensure your actions and your workplace environment is

free from all forms of discrimination including harassment and bullying.

Do not label, categorize or treat others as a member of a different class.

Ensure all decisions (employment, promotion, assignments) are based on job qualifications

(education, training, experience) and merit.

Consult with management if a conflict should arise that you feel is in violation of the laws,

customs, beliefs or policies for any individual.

Report any form of discrimination including hostile environments that you observe or may have

experienced in the workplace.


4.2 Contractors and Partner Companies

GNS recognizes that as the Proponent of the Project it has overall leadership responsibility for advancing

gender equity and diversity in the development of this Project. This will be guided and driven by the

corporation’s overall goals and core values, along with its policies, strategies and initiatives related to

workplace diversity and equity as highlighted earlier in this document.

The implementation and success of the various initiatives outlined in this Plan also depends, however, on

the cooperation and support of a variety of Project participants and stakeholders, including GNS

contractors and their subcontractors, Project workers, government departments and agencies, industry

associations, social and advocacy organizations, and others.

The goals, objectives and requirements of this Plan will be clearly communicated to all organizations and

individuals involved in the Project. Given for example that the construction of the Project itself, and

therefore any associated hiring, will be primarily undertaken by contractors, these companies will clearly

have a key role in implementing this Plan and seeking to achieve its underlying goals and objectives. GNS

will facilitate this by requiring contractors and subcontractors to be fully aware of and implement the

various measures and principles outlined herein, by ensuring that these factors are considered in the

procurement processes for the Project, through on-going communications and oversight, and through its

continued participation in existing forums and initiatives that help to increase the involvement of women

and other underrepresented groups in such projects. All contractors will be required to take proactive

steps to increase the involvement of women through their respective hiring practices, and to implement

the measures outlined in this Plan in a timely and effective manner. This will include strategies and

procedures for the creation and maintenance of a safe, respectful and inclusive workplace, including

associated policies and procedures and their communication, worker orientation and training, ensuring

appropriate facilities and equipment, addressing any incidents or complaints, and other such measures as

outlined in this Plan. All contractors will also be required to track and regularly report to GNS as requested

on their various equity and diversity initiatives and outcomes.

As an equal opportunity employer, GNS will therefore ensure that contractors and partner companies will

be informed of our Women’s Employment Plan as well as the GNS code of conduct. GNS will work with

contractors and partner companies and organizations to promote the Women’s Employment Plan and its

initiatives.


5.0 Monitoring and Reporting

GNS also recognizes the importance of monitoring and evaluating its women’s employment objectives

and initiatives, and to making adjustments to this Plan as required based on the principle of continuous

improvement and through an on-going adaptive management approach. The company will use various

means to gather information on the outcomes of its initiatives, including discussions with workers,

supervisors and management which may take the form of workplace committees, focus groups (both

formal and informal), exit surveys, and other discussions.

GNS will establish a four-person committee comprised of the General Manager, the Human Resources

Manager and two other senior staff to monitor the Women’s Employment Plan and program. This

Committee will meet at least annually to review the company’s performance. Any recommendations for

changes arising from this feedback will be considered with respect to safety, productivity and cost, and a

plan for execution of any necessary corrective measures will be developed.

GNS will also report to the Government of Newfoundland and Labrador on the Plan’s implementation and

outcomes. Specifically, this will involve regular reporting to the Minister Responsible for the Status of

Women on the implementation of the various initiatives outlined in this Plan. These reports will include

employment data by identified group and occupation (NOC) during the implementation phases of the

Project. The reporting will indicate the number of individuals and total work hours undertaken by women

during the Project for the reporting period in question.

It is proposed that this reporting will begin upon commencement of Project construction and will extend

into the initial 2-3 years of operation, until such time as the entire Project workforce is in place and has

largely stabilized. The nature and frequency of this reporting will be determined and developed in

consultation with the Women’s Policy Office.

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